Here is TLC’s response to Southeastern and Southern Rail’s ticket office closure consultation:
Tonbridge Line Commuters are a Railfuture affiliated rail user group covering the Tonbridge area (Hildenborough, Tonbridge, Paddock Wood, Leigh, Penshurst, Edenbridge). We have been representing passengers since 1959.
This issue has been brewing for several years. In discussions with Southeastern about staffing levels at ticket offices (that were frequently closed during scheduled opening hours), we were told that it was wrapped up in the negotiations with the RMT. This was at a time when the Rail Delivery Group/DFT were denying the RMT’s claims on ticket offices.
This consultation feels incredibly rushed, with an exceptionally short response time, timed when Parliament is about to enter recess and people will be taking summer holidays. These closures were reported in the media last year and we responded with an article on our website (19/06/22 – https://tonbridgecommuters.org.uk/5-reasons-why-getting-rid-of-rail-ticket-offices-is-a-bad-idea-and-a-strike-tip-for-flexi-season-ticket-holders/). We are concerned about the Government’s intention to honour the report you produce as we have been made aware that even before this consultation was announced, some staff had received new identification badges containing the new title. This feels like the outcome has already been decided. It is also illogical that this exercise is being carried out piecemeal with very different outcomes between train operating companies. It is a missed opportunity for Great British Rail to start bringing the system together. Shrewsbury proves this point by being a station in England, but it will retain its ticket office as it is operated by Transport for Wales (https://www.shropshirestar.com/news/transport/2023/07/05/these-are-the-ticket-offices-that-will-remain-open-in-shropshire-under-mass-closure-plans/).
As it stands, ticket offices are a contractual obligation, requiring this consultation to change them. The proposed multi-skilled roles will lose this protection and so our fear is that this will pass and then staff attrition and hiring freezes will slowly see staff numbers ebb away, never to return. There are already a number of stations that have had this fate and there are a number of ticket offices where the published opening hours are frequently missed. If this is genuinely about upskilling staff and enabling more people to help, then there should be no objection to replicating that contractual obligation for the new roles.
Technology
The approach being promoted by the rail industry is for greater self-service. We welcome this approach as technology should be levied to help passengers. For those that are comfortable purchasing online, or with their smart phone, smart card, this should be encouraged. It frees up staff to spend time on those that may need assistance, be it help with selecting the correct ticket or purchasing a ticket where the option is not available via a ticket machine or online.
Two things need to happen in order to make this staff transfer work, the rail fare system needs to be radically simplified to prevent poor outcomes. It is too easy to buy the wrong type of ticket. Ticket machines often show tickets in an illogical order. For example, Southeastern used to show via high speed 1 routes as the default option, even when that would be a totally illogical journey as it would take significantly longer and cost substantially more than a direct journey would (https://www.timeslocalnews.co.uk/local-news/good-news-for-southeastern-commuters/). The second part is that the infrastructure needs to be invested in. Bar code e-tickets are a relatively new development, and it is not so long ago that the Government was mandating train operators to invest in Oyster style Smartcards, which do not appear to have had very good take up and is now wasted capital.
Apps need to be updated too. It can be quite fiddly to load a ticket onto a smart card, or you have to select a train a couple of hours in advance to allow it to be loaded onto a smart card. The apps tend to be clunky, and the level of IT literacy needed to make these work is too high. Information is stored illogically, and users sometimes have to check 3 or 4 different pages to get nuggets of information that should all be visible from one point.
Ticket Vending Machines (‘TVM’) suffer from limited functionality, poor tracking and poor user interfaces. It can be incredibly frustrating for users who try to buy something other than a simple, regular journey. There are a number of tickets that cannot currently be purchased by a TVM, such as ex staff privilege fares, CIV tickets (connections to Eurostar) or Boundary fares. Indeed rail operators have been taken to court over the failure to offer Boundary Fares and so adding this functionality would be well over due (https://www.standard.co.uk/news/transport/court-class-action-rail-passengers-paid-twice-boundary-fares-b1066833.html). Often it is impossible to go back a stage and so if a user enters something incorrectly, they must start the process again. With the increase in self-service, this could well see even bigger queues at TVM’s that we currently see, which puts pressure on those within the queue, particularly close to trains arriving. When this is combined with fewer services because of post COVID timetables, this can create significant pinch points and a poor, stressful experience for passengers. Passengers then may feel the need to turn up earlier to the station and so this is a reduction in the passenger experience at a time when the railway is becoming less attractive for users.
The technology should be in place prior to staff being redeployed. If nothing else, just to test it works and allow users to become more familiar with it.
Disabled passenger concerns – specifically blind people
Ticket offices provide a known easy to navigate location to seek help from a trusted person. Guide dogs are often taught to be able to navigate to this area, and someone with accessibility needs can trust that the person in the ticket office is a member of staff. Furthermore, ticket offices are often equipped with equipment such as hearing aid induction loops.
Compare this to an ‘on the concourse’ experience – although there may be an ‘area’ with machines, it can be hard to distinguish where this is compared to a ticket office. Furthermore, once in that area it can be difficult for someone be confident that they are speaking to a member of staff rather than a member of the public – especially if they have reduced vision. The concourse can be a very noisy environment, and without an induction loop it could be very difficult for the person to hear. All of this serves to take away existing accommodations that many people rely upon – taking away their independence without providing a suitable fit-for-purpose alternative.
Working Environment for staff
Assisting in ticket offices has been a useful way of helping disabled/long term sick members of staff back to work. For example, conductors who are not signed off as being able to work a train, can sit in a ticket office and cover other members of staff. There may be disabled members of staff who are able to sit in a ticket office but may not be mobile enough to cope standing on a concourse all day. What provision is being made for them? It is a stated aim for the Government to help people getting back to work and so how is this consistent with that message (https://www.gov.uk/government/news/new-plans-to-boost-health-in-the-workplace-to-keep-people-in-work)?
Refunds
As it stands, staff in ticket offices can refund tickets without an administration charge (https://www.nationalrail.co.uk/tickets-railcards-and-offers/buying-a-ticket/changing-cancelling-and-getting-a-refund-for-tickets/). With this functionality lost, will people be forced to apply online or via the post, when administration charges often make the process worthless? This would not be consumer friendly.
Comparison with other industries
Presently, Financial Services regulation is being increased through the ‘Consumer Duty’ (https://www.fca.org.uk/publications/policy-statements/ps22-9-new-consumer-duty). The principles of this are to act in good faith towards customers and to avoid foreseeable harm. In that context, this proposal would not stand up to scrutiny as it creates a much worse outcome for vulnerable people without providing a benefit to anyone. There is nothing in the ticket office system that stops other methods being developed.
Southeastern
Southeastern stations have experienced significant staff shortages in ticket offices and so given Government financial constraint, it seems fanciful that staffing levels will improve post this consultation and so that is a big concern for our members. There do not appear to be enough staff currently to fulfil roles and this creates shortages, both on a regular basis and on the ad-hoc basis when staff are ill or take holidays.
The equality assessment seems to lack rigour. Of the 9 characteristics shown, New Cross has 8 ticked, with only marriage/civil partnership shown as no. Chelsfield and Knockholt however only has 2 ticked of age and disability. One of the other characteristics is religion. Using local stat.co.uk, all three areas have similar levels of people declaring no religion at 24.3%, 23.10% and 22.10%. Is this significant enough to demonstrate that only one of these stations need to consider religious characteristics? Southeastern are claiming that all stations will only experience a low impact from an equality point of view. All stations consider age and disability to be potential issues and so this lacks credibility, especially given the accessibility comments we touch on with some individual stations below. This, combined with the comments from Southeastern about monitoring things afterwards, make this feel like a human experiment and it risks people being alienated and put off from travelling by rail, which is an outcome nobody wants.
Chelsfield station – 16% of tickets are purchased in person either in the ticket office or using the TVM. This is despite the pay as you go ‘tap in’ option being available. 15% of tickets are purchased online and perhaps are collected at either the ticket office or via the TVM and so the quoted numbers may be higher. Based on the latest ticket sale information (2022) over 10,000 tickets were sold via this ticket office.
The proposal reads that “If customers are unable to purchase tickets from the channels listed above or via our app or website, they can visit the nearest Southeastern Travel Centre at Sevenoaks.”. It is unclear how this will work. Will passengers be expected to drive to Sevenoaks, or will they be permitted to travel without a ticket in order to buy a ticket from the ‘travel centre’. Or worse, will they be expected to buy a ticket to Sevenoaks, only to buy the ticket they originally wanted? If someone is travelling to London, travelling out to Sevenoaks would be a major inconvenience. Who does this policy benefit? Nobody, but it potentially inconveniences those with accessibility issues significantly. For example, someone with accessibility requirements may not be able to travel to Sevenoaks via other means. The train, and staffing associated with it, is what would let them travel. So, they would be unable to travel under these proposals, which is surely an undesirable outcome?
The Access for all programme (https://www.gov.uk/government/collections/access-for-all-programme) is designed to help disabled people travel, using the railway. Removing the staff (as we fear) means all that progress becomes wasted funds at a time when the Government is citing financial pressure.
Chelsfield only has 1 TVM, which as we have already established are in desperate need of upgrades. For this to work, there should be more TVM’s made available. We understand that new TVM’s are being sourced but these should be in place before removing the ticket office.
Under accessibility, it is pretty clear that Southeastern expect there to be periods of time when staff will not be available by making a mobile assist team available. This will be the end of turn up and go for disabled passengers, as they may face an intolerable wait for staff to be available. This seems to contrast with the equality assessment that reads they expect ‘low impact expected’.
New Cross Station – see our comments on Chelsfield but here the numbers are even more interesting. Despite being in the Oyster, pay as you go region, over a quarter of tickets are still being bought using the ticket office. In what business would it be logical to cut off a quarter of your customers? Some may switch to alternative methods, but given those alternative methods are currently available and not being used, what is the reasoning here? Southeastern have offered no analysis as to why this makes sense.
We have queried this with Steve White, Managing Director of Southeastern who has told us there are “no obvious differences why New Cross should be different. Consultation may reveal a local factor”. This would suggest a political decision rather than a commercial decision as it is not logical to knowingly inconvenience over a quarter of your customers. There has been no attempt to understand the situation here, the ticket office just gets swept away like every other station around. If we assume that these plans proceed as stated and that there are staff on the concourse able to sell tickets, how will they cope if there is no change in user behaviour? It is essential to understand why New Cross has not followed the trend of other stations, rather than just ride roughshod over the 8 protected characteristics, Southeastern have identified.
Knockholt Station – 23% of tickets are bought using the ticket office, again whilst other options are available. No analysis is provided, it’s simply part of the sweeping brush to close all ticket offices.
Southern
Sadly, Southern have failed to provide any data or any context to support their decision, which is lamentable.
Edenbridge Town is often unstaffed, despite having published opening hours. This causes significant issues, especially for local schoolchildren who are the main constituent group on the Tonbridge to Redhill line (there is one TVM at Edenbridge with members often reporting its unreliability). Indeed, latest developments are that schoolchildren are required to provide a hard copy of a photo card so that they can buy season tickets. With the station likely to face lower staff availability post these proposals, how are they supposed to do this? The lack of investment in rail infrastructure is shown by the fact that one member’s daughter has a 16+-17 saver card, which used an ID check against her passport number, yet the railway is still insisting on hard photocopies. This demonstrates that the investment should be made in making systems work before removing staff.
Redhill – has a number of entrances and exits and suffers from fare evasion. With reduced staff, this may result in greater fare evasion and so it is possible that this exercise will lose more than it saves.
Conclusion
We are not opposed to a phased modernisation in stages based on proven technology and passenger experience. A more methodical approach would protect the rail industry’s reputation and reduce the risk of judicial review of rushed decisions. We are aware of legal attempts to challenge these proposals, and this is not a healthy way to run a public service. We are not opposed to attempts to save money but there is such little goodwill within the rail industry that we simply cannot trust this process and fear the outcome.
The data provided by Southeastern show that there are some stations where ticket offices have become surplus to requirements and so it is logical to change approach to suit the change in times. What is essential though is that there is human contact on the railway that can assist passengers who may need help. This can be easily achieved by adding the same contractual requirements on to the new platform staff role as exists for the ticket office currently.
It would be an outrage is in 2023, people were being shut out of a railway that 180 years ago brought social mobility to huge swathes of the population. There must be a better way and we urge a rethink. An example would be the London Overground, managed by Transport For London (TFL). TFL staff stations from first train to last (https://tfl.gov.uk/corporate/publications-and-reports/london-overground-performance), why should any other London Metro service be any different? Functionally, they are the same, heavy rail in London.
We are concerned that this consultation is not genuine in its aims and is a Trojan horse, designed to reduce staff numbers, at any cost, purely to save money. There seems to be very little regard for anyone who may need assistance and there is an overreliance on systems that have been barely tested or need an upgrade. This consultation therefore is premature and should be led by technological improvements that may result in an exercise like this, becoming more valid.